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Compliance Into the Weeds

Compliance into the Weeds: Carrots and Sticks in Washington: Antitrust Whistleblowers and an FCPA SOL Extension

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at two recent developments sending a common message to compliance teams.

First, DOJ antitrust official Daniel Glad warns that a new Antitrust Whistleblower Awards program and increased pursuit of prison time for individuals compress companies’ timelines to investigate and self-disclose, because insiders may report first and cost those firms potential leniency. Second, Senate Democrats, led by Elizabeth Warren, propose the FCPA Reinforcement Act to extend the FCPA statute of limitations from five to 10 years, creating an eight-year window, with the aim of preserving future enforcement capacity for misconduct occurring now. They connect these “sticks” with “carrots,” such as fast declinations for self-disclosure, emphasizing the need for robust compliance programs, a strong reporting culture, prompt investigations, and clear decisions on disclosure, regardless of who controls Washington.

Key highlights:

  • Two Washington Signals
  • Antitrust Whistleblower Push
  • FCPA Reinforcement Act
  • Carrots, Sticks, and Culture
  • Why Internal Reporting Matters
  • Self Disclosure Through Line

Resources:

Matt in Radical Compliance here and here

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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FCPA Compliance Report

FCPA Compliance Report – FCPA Enforcement Shifts: Volatility and Uncertainty

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode,  host Tom Fox welcomes Anik Shah, Director & Senior Legal Counsel at Sandisk, for an insightful discussion about the pivotal changes and enforcement actions around the FCPA in 2025 and their implications for 2026.

In 2025, Anik Shah, a preeminent authority on FCPA and anti-corruption enforcement, offers a strategic perspective on the evolving compliance landscape. Given the recent uncertainties following an executive order and the dismissal of high-profile cases, Shah underscores the necessity for companies to maintain robust anti-bribery and anti-corruption controls, especially with potential reprioritization by the Department of Justice. He advocates a proactive risk management approach, emphasizing the importance of third-party risk management and comprehensive training to anticipate and mitigate potential FCPA issues. As enforcement focus shifts toward addressing cartel and transnational criminal organization activities, Shah advises companies to integrate anti-money laundering processes into their compliance strategies to align with global anti-corruption efforts.

Key highlights:

  • 2025 FCPA Enforcement Shifts and Uncertainty
  • Voluntary Self-Disclosure Policy Revolution in 2025
  • Cartel Risk Mitigation through Compliance Integration
  • Central Asia Construction Projects: Anti-Corruption Measures
  • Proactive Measures: Fostering Anti-Corruption Compliance Awareness

Resources:

Anik Shah on LinkedIn

Sandisk

Tom Fox

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Returning to Venezuela on Amazon.com